Asbestos Standards: Rules and Limit Values at a Glance
Technical rules, analytical methods, and regulatory thresholds for asbestos in mineral raw materials: from Germany, Austria, the EU, Italy, and California (CARB), compared and sourced.
This page documents the technical rules, analytical methods, and regulatory thresholds that govern asbestos in mineral raw materials in Germany, Austria, the EU, Italy, and California (USA). It is laid out as a factual reference: every value is backed by a primary source and placed along two axes: jurisdiction and protection goal. For its application to the Burgenland affair, see the dedicated section on the Burgenland page.
Note: a technical reference, not legal advice. For specific questions about obligations and measures, see the contact page.
Limit and threshold values compared
Instrument
Value
Value type
Jurisdiction
Applies to
Legal effect
Source
GefStoffV § 11 Abs. 1 Nr. 1
0,1 Massen-%
Threshold value
Germany
Asbestos mass content in the material (mineral raw materials and mixtures/products made from them)
Above 0.1 percent, extraction, processing, further processing, and reuse are prohibited (§ 11(1) no. 1 GefStoffV); also the reference figure for the asbestos mass-content determination under TRGS 517.
Acceptance concentration, associated with the acceptance risk 4:10,000; below it the risk is low and acceptable. For asbestos it was not lowered to the general post-2018 acceptance risk of 4:100,000.
Tolerance concentration, associated with the tolerance risk 4:1,000; above it the risk is high and unacceptable — activities are generally impermissible.
Asbestos mass content in waste (removed material or material classified as waste)
At/above 0.1 % the hazard-relevant property HP 7 applies (asbestos = Carc. 1A/H350); the material is thereby hazardous waste and is assigned to an asbestos key number (SN 31436 gn or 31437-40 gn). Governs disposal, NOT a product sales ban.
Asbestos content in surfacing material (surfacing aggregate)
Material with asbestos content >= 0.25 % may not be used/sold as surfacing material (§ 93106(c)); 0.25 % = the lower detection limit of PLM Method 435 ('less than 0.25 %' = not detectable).
Asbestos content in surfacing material (historical original version)
Original limit (1990/1991); tightened to < 0.25 % by CARB decision July 2000 (effective 2001). Residual reference in § 93106(f)(9)(A)(3) where compliant material is unavailable.
The 0.1 % by-mass material threshold that serves as the yardstick in the Burgenland affair comes from the German Hazardous Substances Ordinance (today § 11 (1) No. 1 GefStoffV; the earlier location, Annex II No. 1, lapsed with the amendment of 4 December 2024) and is given technical form by TRGS 517. Austria has no material threshold of its own. The authorities fall back on the German procedure and thereby implicitly import the 0.1 % yardstick.
A ban is not a classification. The actual prohibition on placing on the market and use is delivered by REACH Annex XVII Entry 6. Its applicability to naturally occurring asbestos in mineral raw materials is, however, disputed: Entry 6 covers asbestos that has been 'intentionally added', and naturally occurring contamination (for instance in serpentinite) falls outside it according to the European Parliament's answer (E-008194/2012). The CLP Regulation, in turn, classifies and labels (Carcinogen 1A, H350). It bans nothing. REACH Entry 28 does restrict the supply of carcinogens to the general public above 0.1 %, but does not cover asbestos: with Entry 6, asbestos has a restriction of its own and is not listed in Appendix 1.
The 0.1 % travelling threshold. The same numerical value, 0.1 % by mass, recurs across several instruments without triggering a single, uniform legal consequence: as the GefStoffV material threshold (status 'asbestos-containing'), as the CLP classification limit (labelling obligation), and in Italian waste law, like Austria's, as a hazard threshold (HP 7, Regulation (EU) 1357/2014), but in none of these cases as a content-based sales ban. Not to be confused with it is the Italian indice di rilascio (I.r. ≤ 0.1): the same digits, but a dimensionless release ratio (a different physical quantity).
Two axes, not one. Material mass content (% by mass) and airborne fibre concentration (fibres/m³) are physically distinct quantities. The EU Asbestos Directive (EU) 2023/2668 lowers the binding occupational limit value (0.1 → 0.01 → 0.002 fibres/cm³); Austria transposes this through the Limit Values Ordinance (10,000 fibres/m³ since 31 December 2025, 2,000 fibres/m³ from 21 December 2029). These air limits say nothing about the asbestos content of a material, and vice versa.
The standards in detail
Group by
Grouped by country
EU
CLP-VO (EG) 1272/2008: Regulation (EC) No 1272/2008 (CLP) on classification, labelling and packaging of substances and mixtures
Europäisches Parlament und Rat der EU · EU · EU regulation
Scope. Harmonised classification, labelling and packaging of substances and mixtures placed on the EU market.
What it regulates. Asbestos carries an EU-wide harmonised classification (Annex VI, Table 3, Index 650-013-00-6): Carcinogen Cat. 1A (H350) and STOT RE 1 (H372). The generic concentration limit for Carc. 1A/1B substances is 0.1 % (Annex I, Part 3, Table 3.6.2).
Where it ends. The legal effect is a classification and labelling obligation (hazard communication) — NOT a market or use ban. The prohibition is provided by REACH Annex XVII Entry 6.
Our reading: Table renumbering: in the current consolidated CLP the list is „Table 3“ (formerly „Table 3.1“; changed by Reg (EU) 2019/521). Older reproductions say „Table 3.1“ — same list, not a discrepancy.
REACH Anh. XVII Eintrag 28: REACH Regulation (EC) No 1907/2006, Annex XVII Entry 28 — general carcinogen restriction (Cat. 1A/1B)
Europäisches Parlament und Rat der EU · EU · EU regulation
Scope. Restricts supply of substances classified Carcinogen Cat. 1A/1B to the general public at/above the (specific or generic) concentration limit; requires the marking „Restricted to professional users“. Supply to professional and industrial users remains permitted.
What it regulates. Appendix-bound: Entry 28 covers the substances listed in Appendix 1 (Cat. 1A) / 2 (Cat. 1B). The generic limit is 0.1 % (CLP Annex I).
Where it ends. Does NOT apply to asbestos: asbestos is not listed in Appendix 1 (checked) — it has its own, more far-reaching restriction in Entry 6. Even where Entry 28 applied, it would restrict only public supply, not commercial supply.
Our reading: Checked: Appendix 1 (the Cat. 1A list for Entry 28) does not contain asbestos — no „asbestos“ entry, none of the six fibre types, not Index 650-013-00-6 (instead e.g. chromium(VI), nickel compounds, diarsenic trioxide, benzene). Confirms Entry 28 does not catch asbestos.
REACH Anh. XVII Eintrag 6: REACH Regulation (EC) No 1907/2006, Annex XVII Entry 6 — asbestos fibres
Europäisches Parlament und Rat der EU · EU · EU regulation
Scope. Prohibits the manufacture, placing on the market and use of asbestos fibres and of articles and mixtures to which these fibres are added intentionally (six fibre types with CAS numbers: crocidolite, amosite, anthophyllite, actinolite, tremolite, chrysotile). Articles installed before 1 Jan 2005 may remain in use until end of life.
What it regulates. This is the actual placing-on-the-market and use prohibition — the legal effect that CLP classification lacks.
Where it ends. Covers intentionally added asbestos. Its applicability to naturally occurring asbestos in mineral raw materials is disputed (see editorial note).
Our reading: Wording: „added intentionally“ — not „deliberately added“; it also covers articles, not only mixtures. Disputed and well-grounded: naturally occurring asbestos as an impurity in mineral raw materials (e.g. serpentinite) does NOT fall under Entry 6 on the wording, because the fibres are not intentionally added (per the European Parliament answer E-008194/2012 and the Irish HSA). For such materials the occupational regime (Directive 2023/2668) governs instead.
RL (EU) 2023/2668: Directive (EU) 2023/2668 of 22 November 2023 amending Directive 2009/148/EC (protection of workers from asbestos at work)
Europäisches Parlament und Rat der EU · EU · EU directive
Scope. Occupational protection: lowers the binding workplace exposure limit (8-h TWA) for asbestos and modernises measurement. Not a classification and not a market restriction.
What it regulates. Lowers the limit from 0.1 to 0.01 fibres/cm³ (no transition period; transpose by 21 Dec 2025). After a maximum 6-year transition, electron microscopy becomes mandatory and the value drops to 0.002 fibres/cm³ (excluding thin fibres) or 0.01 fibres/cm³ (including thin fibres, width < 0.2 µm); aligned with 21 Dec 2029.
Where it ends. A pure occupational-limit instrument. Importantly: where REACH Entry 6 does not catch naturally occurring asbestos, this workplace limit is the operative control for exposure during extraction and processing.
GefStoffV § 11 Abs. 1 Nr. 1: Hazardous Substances Ordinance (GefStoffV), § 11(1) no. 1 — prohibition of activities involving asbestos-containing mineral raw materials above 0.1 % mass content
Bundesregierung (Deutschland); konsolidierte Fassung: Bundesamt für Justiz / gesetze-im-internet.de · Germany · Law / ordinance
Scope. Prohibits the extraction, processing, further processing, and reuse of naturally occurring mineral raw materials (and mixtures/products made from them) with an asbestos mass content of more than 0.1 percent. The legal basis of the 0.1 % material threshold, technically concretised by TRGS 517.
What it regulates. Defines the asbestos mass content above which extraction and processing are prohibited (more than 0.1 percent).
Where it ends. A material threshold (mass content) — not an airborne exposure limit (cf. § 11a(6): 1,000 fibres per cubic metre) and not a general content-based sales ban beyond the activity prohibition.
Our reading: Until the GefStoffV amendment of 4 Dec 2024 the 0.1 % rule sat in Annex II no. 1, which has since been repealed ("weggefallen"). Current location: § 11(1) no. 1. TRGS 517 (2013) still cites the old location.
IFA 7487: Method for the analytical determination of low mass contents of asbestos fibres in powders, dusts, and fine powders by SEM/EDX (reference no. 7487)
Institut für Arbeitsschutz der DGUV (IFA), IFA-Arbeitsmappe „Messung von Gefahrstoffen" · Germany · Analysis method
Scope. Analytical determination of low asbestos-fibre mass contents in powders, dusts, and fine powders by scanning electron microscopy with energy-dispersive X-ray analysis (SEM/EDX); applied among others to naturally occurring mineral raw materials.
What it regulates. Provides the "asbestos mass content" used in TRGS 517 Annex 2 and compared against the GefStoffV 0.1 % value; WHO fibres are counted (length > 5 µm, diameter < 3 µm, L:D > 3:1).
Where it ends. Determines a material mass content — not an airborne concentration (F/m³). Not to be confused with "Aus der Arbeit des IFA Nr. 0038 – Asbestos fibres in rock dusts", the supplementary fibre-identification catalogue.
TRGS 517: Technical Rules for Hazardous Substances (TRGS) 517 – Activities involving potentially asbestos-containing mineral raw materials and the mixtures and products made from them
Ausschuss für Gefahrstoffe (AGS); bekannt gegeben vom BMAS im Gemeinsamen Ministerialblatt · Germany · Technical rule
Scope. Applies to activities involving potentially asbestos-containing mineral raw materials (Annex 1) and mixtures and products made from them — in particular extraction and processing in quarries (ballast, chippings, crushed sand, filler), further processing in construction, recycling/reuse in road-building, and natural-stone working.
What it regulates. Primarily an occupational-safety rule. Annex 2 provides four analytical procedures for the asbestos mass content; method 2 — decisive for dusty bulk material — measures the asbestos fraction in the respirable dust (E-dust) from a standardised dusting test and extrapolates it to the drop mass, evaluated by IFA procedure 7487 (SEM/EDX). Exposure assessment follows the asbestos ERB (acceptance/tolerance concentrations from TRGS 910).
Where it ends. Covers geogenic (naturally occurring) asbestos as a trace constituent of mineral raw materials. To be distinguished from demolition, remediation, and maintenance work on deliberately asbestos-added building products — that is the domain of TRGS 519. The "asbestos mass content" is method-defined and does not necessarily equal the mass fraction of asbestos minerals.
concretizes → GefStoffV § 11 Abs. 1 Nr. 1; references method → IFA 7487
TRGS 519: Technical Rules for Hazardous Substances (TRGS) 519 – Asbestos: demolition, remediation, or maintenance work
Ausschuss für Gefahrstoffe (AGS); bekannt gegeben vom BMAS im Gemeinsamen Ministerialblatt · Germany · Technical rule
Scope. Demolition, remediation, and maintenance work ("ASI work") on asbestos-containing materials — primarily deliberately asbestos-added building products in buildings and technical installations — including the associated waste handling; concretises the relevant requirements of the Hazardous Substances Ordinance.
What it regulates. Governs approval/competence, notification, protective-measure, and worker-protection duties for ASI work on asbestos.
Where it ends. Counterpart to TRGS 517: TRGS 519 covers built-in / deliberately-added asbestos products and ASI work; geogenic asbestos in mineral raw materials is the domain of TRGS 517. Both rest on the same asbestos ERB (TRGS 910).
TRGS 910: Technical Rules for Hazardous Substances (TRGS) 910 – Risk-based concept of measures for activities involving carcinogenic hazardous substances
Ausschuss für Gefahrstoffe (AGS); bekannt gegeben vom BMAS im Gemeinsamen Ministerialblatt · Germany · Technical rule
Scope. Cross-substance, risk-based concept of measures for activities involving carcinogenic hazardous substances; sets the three risk bands (low/medium/high) and the substance-specific acceptance and tolerance concentrations (Annex 1, Table 1) as assessment benchmarks under § 10(1) GefStoffV.
What it regulates. Derives the substance-specific concentrations from each substance's exposure–risk relationship (ERB); for asbestos the acceptance concentration remains anchored to the 4:10,000 risk (note "b)") and was not lowered to the general post-2018 acceptance risk of 4:100,000.
Where it ends. Sets fibre concentrations in workplace air (F/m³) — not a material threshold (that is GefStoffV) and not an asbestos-operations rule of its own (it points to TRGS 517 and TRGS 519).
VDI 3492: VDI 3492 – Indoor air, ambient air – Measurement of inorganic fibrous particles – Scanning electron microscopy method
VDI/DIN-Kommission Reinhaltung der Luft (KRdL) · Germany · Analysis method
Scope. Determines the number concentration of inorganic fibrous particles in indoor or ambient air and classifies them (chrysotile, amphibole asbestos, calcium sulfate/gypsum, other inorganic fibres) by SEM/EDXA on filter samples. Fibre per the WHO definition (L > 5 µm, D < 3 µm, L:D > 3:1).
What it regulates. SEM/EDXA fibre counting on air-filter samples; detection limit about 300 m⁻³, analytical sensitivity 100 m⁻³ under the guideline's standard conditions.
Where it ends. Air (immission) measurement — not for dust settled on surfaces (VDI 3877) and not for determining the asbestos content of products (VDI 3866). No legal limit; the figures given are method performance values.
Our reading: Title change: the 2026-01 edition was retitled; the 2013-06 edition carried the longer title (Messen von Innenraumluftverunreinigungen – Messen von Immissionen – …). Cite by edition date; 2026-01 supersedes 2013-06.
VDI 3866: VDI 3866 – Determination of asbestos in technical products
VDI/DIN-Kommission Reinhaltung der Luft (KRdL) · Germany · Analysis method
Scope. Guideline series for detecting and determining asbestos in technical products (benchmark: deliberately added, from about 1 mass-%). Part 1: sampling and sample preparation (2021-12); Part 2: infrared spectroscopy (2001-10); Part 4: phase-contrast microscopy/PLM (2002-02); Part 5: scanning electron microscopy SEM/EDXA (2017-06). The originally planned Part 3 (X-ray diffraction) was not realised.
What it regulates. Part 5 (SEM/EDXA) is the reference method: qualitative asbestos detection distinguishing chrysotile from amphibole asbestos; concentrating the sample lowers the detection limit below 1 % (Annex B). Part 4 (PLM) is fast but unreliable for fibres below about 1 µm in diameter.
Where it ends. A method series for bulk material and products — not for air (VDI 3492) and not for dust settled on surfaces (VDI 3877). The 1 % figure is a methodological benchmark, not a legal limit.
VDI 3877: VDI 3877 – Measurement of indoor pollution – Measurement of fibrous dusts settled on surfaces
VDI/DIN-Kommission Reinhaltung der Luft (KRdL) · Germany · Analysis method
Scope. Determines the number of fibre structures in dust settled on surfaces and classifies them (e.g. chrysotile, amphibole asbestos, other inorganic fibres) by SEM/EDXA on contact/tape samples; semi-quantitative assessment. Part 1: sampling and analysis (2011-09); Part 2: sampling strategy and evaluation (2014-12). Fibre here L:D > 3:1 (broader than the alveolar definition in VDI 3492).
What it regulates. SEM/EDXA on tape samples; detection limit about 40 fibre structures per cm².
Where it ends. Explicitly not suitable for assessing indoor-air burden from tape samples and not for determining the asbestos content of products — distinct from VDI 3492 (air) and VDI 3866 (products). The 40 structures/cm² is a method detection limit, not a health limit.
Our reading: Correct designation: Innenraumverunreinigungen (settled dust), not Innenraumluftverunreinigungen.
Austria
AVV SN 31437-40 gn: Waste Catalogue Ordinance 2020 (AVV), key number 31437-40 gn — asbestos waste, asbestos dust
BMK (Österreich) · Austria · Law / ordinance
Scope. Asbestos waste and asbestos dust as hazardous, non-declassifiable waste: key number 31437-40 gn, waste type 'mineral-fibre waste with hazard-relevant fibre properties', specification 40 = 'asbestos waste, asbestos dust'.
What it regulates. 'gn' = hazardous, cannot be down-classified.
Where it ends. SN 31437-40 = asbestos waste/dust (weakly bound + loose). Distinct from neighbouring asbestos key numbers: 31412 (asbestos cement), 31413 (asbestos-cement dust), 31436 gn (asbestos-containing excavated material and contaminated-site asbestos waste), 31437-41 (man-made mineral fibre waste).
Our reading: For asbestos-containing material, the waste-law assignment depends on the physical form. For removed asbestos-containing excavated material (for instance tunnel spoil containing naturally asbestos-bearing rock) and asbestos waste from contaminated sites with more than 0.1 % asbestos by mass there is a dedicated key number, SN 31436 gn, created to monitor the landfilling of such waste. SN 31437-40 gn, by contrast, covers asbestos waste and asbestos dust (weakly bound and loose asbestos waste). The 0.1 % by-mass threshold for classification as hazardous waste follows from the CLP classification of asbestos as a category 1 carcinogen (H350). The AVV requires assignment to the most specific waste type possible (Annex 2, general assignment criteria) and, in case of doubt, assigns to the hazardous waste type on the precautionary principle where a hazard-relevant property cannot be excluded. The applicable key number in the individual case is to be determined against Annex 1.
AWG 2002: Waste Management Act 2002 (AWG 2002), § 2(1) (concept of waste) and § 1(3) (public interest)
Nationalrat (Österreich) · Austria · Law / ordinance
Scope. Fundamental definition of when a movable thing is legally "waste", and thereby the entry gate to the waste regime (collection, storage, transport, treatment, disposal).
What it regulates. Two concepts of waste side by side (§ 2(1)): subjective (the holder intends to discard the thing or has done so) and objective (its collection, storage, transport and treatment as waste is required so as not to impair the public interests under § 1(3)). § 1(3) enumerates those public interests, expressly including that otherwise human health may be endangered or unreasonable nuisance caused.
Where it ends. Defines waste status, not the waste-law hazard classification; that runs through the AVV (Annexes 1/3/4) in conjunction with Regulation (EU) 1357/2014 (from 0.1 % asbestos by mass: HP 7). The objective concept of waste is conditional: it applies only in so far as treatment as waste is required to protect the public interest (§ 1(3)), i.e. dependent on a health hazard, not automatic from the asbestos content. No prohibition on placing on the market or product ban (that is REACH/CLP).
GKV (Grenzwerteverordnung): Limit Values Ordinance 2024 (GKV) — Section 4, §§ 21–27 (special provisions for asbestos); asbestos fibre value in Annex I/2025
BMASGPK (Österreich), auf Grundlage § 18 ASchG · Austria · Law / ordinance
Scope. Sets the permissible concentrations of substances in workplace air (MAK/TRK values). Asbestos is governed in Section 4 (§§ 21–27, special provisions); the asbestos fibre value is in Annex I/2025 (substance list).
What it regulates. Asbestos workplace limit: 10,000 F/m³ (= 0.01 F/cm³) since 31 Dec 2025, planned reduction to 2,000 F/m³ (≈ 0.002 F/cm³) from 21 Dec 2029. Implements EU Directive (EU) 2023/2668.
Where it ends. Sets the occupational air limit and work rules — not the waste classification (AVV) and not the measurement method (ÖNORM M 9405, required by GKV § 24).
national counterpart → RL (EU) 2023/2668; refers to → ÖNORM M 9405
MinroG: Mineral Raw Materials Act (MinroG), Federal Law Gazette I No. 38/1999 as amended
Nationalrat (Österreich) · Austria · Law / ordinance
Scope. Mining-law regulation of the extraction and processing of mineral raw materials.
What it regulates. Extraction on the basis of an extraction operating plan (§§ 80 ff.); cessation of extraction under § 85 (referring to the closure-plan provisions §§ 112 ff.); ongoing official supervision under § 175.
Where it ends. § 175 governs supervision (periodic inspection), NOT cessation. The competent authority for exclusively above-ground extraction of landowner-owned (grundeigene) mineral raw materials is the district administrative authority (§ 171(1)); otherwise the default authority is the Montanbehörde (§ 170).
Our reading: A self-asserted task-force figure; the value is formed by analogy to an Umweltbundesamt reference for asbestos remediation and transposed to ambient air - with no published derivation for that transposition. No normative status; documented here, not endorsed - not to be confused with a legal or normatively derived limit.
ÖNORM B 3151: ÖNORM B 3151 – Dismantling of buildings as a standard method for demolition
Austrian Standards International · Austria · Technical rule
Scope. Governs planning and execution of the dismantling of buildings in structural and civil engineering (including line structures and paved areas) to obtain source-separated, low-contaminant waste fractions for recovery/disposal.
What it regulates. Requires the removal of contaminants and interfering substances before mechanical demolition.
Where it ends. Is NOT the asbestos-work standard: for handling asbestos-containing materials, B 3151 explicitly refers to ÖNORM M 9406.
ÖNORM M 9405: ÖNORM M 9405 – Determination of asbestos fibre concentration in air
Austrian Standards International · Austria · Analysis method
Scope. Method for measuring/determining the airborne asbestos fibre concentration (sampling and counting, incl. scanning electron microscopy); the measurement standard required by GKV § 24.
What it regulates. Produces the measurement result (fibre concentration) against which the GKV limit is checked.
Where it ends. A measurement method — does not set the limit (GKV) and does not govern handling/remediation (M 9406).
Our reading: Verify the exact German title against the live Austrian Standards catalogue before publishing (two variants in circulation).
ÖNORM M 9406: ÖNORM M 9406 – Handling of weakly bound asbestos-containing materials
Austrian Standards International · Austria · Technical rule
Scope. Basis for minimising risk when handling weakly bound asbestos-containing materials (sprayed asbestos, asbestos boards, night-storage heaters, asbestos floor coverings); decision support and protective measures for remediation/dismantling and the resulting waste.
What it regulates. The Austrian functional counterpart to part of what TRGS 519 governs in Germany.
Where it ends. Handling/remediation standard for weakly bound asbestos — not the air-measurement standard (M 9405) and not the general dismantling standard (B 3151, which refers to M 9406).
Scope. Part Four: waste management and remediation of contaminated sites. Governs the classification of removed material (demolition debris, excavated soil/rock) as hazardous/non-hazardous and its disposal.
What it regulates. Removed material with asbestos >= 0.1 % (1,000 mg/kg) acquires hazard property HP 7 (carcinogenic, as asbestos is Carc. 1A/H350) and counts as hazardous waste (mirror entry 17 05 03* for soil/rock). Separately: CSC 1,000 mg/kg as the site-remediation trigger (Tab. 1, Annex 5).
Where it ends. A waste-law (and, separately, remediation-law) hazard threshold for REMOVED material - NOT a product sales ban (the product ban follows from L. 257/1992 + CLP/REACH).
Our reading: EER-code correction: '17 05 08' is NOT the asbestos code but 'railway-ballast stone' (non-hazardous). For asbestos-contaminated soil/rock the mirror pair 17 05 03*/17 05 04 applies; deliberately asbestos-containing building materials are absolute-hazardous (17 06 05*/17 06 01*) with no 0.1 % test.
D.M. 14.5.1996, Allegato 4: Ministerial Decree 14 May 1996, Annex 4 - Criteria for classifying and using 'green stones' according to their asbestos content
Ministero della Sanita (di concerto con il Min. dell'Industria) · Italy · Law / ordinance
Scope. Annex 4 governs the classification and use of 'green stones' (serpentinites) according to their asbestos content and, above all, their fibre-release potential.
What it regulates. Release index: I.r. = % asbestos liberated / % relative density (dimensionless). Material is 'non pericoloso' when I.r. <= 0.1.
Where it ends. Stone classification by release potential for the extraction/use of natural rock - NOT a product sales ban. The value I.r. <= 0.1 is a DIMENSIONLESS ratio, a DIFFERENT quantity from the waste-law 0.1 mass-% (same digit, different physical quantity).
CARB ATCM 17 CCR 93106: Asbestos Airborne Toxic Control Measure for Surfacing Applications (Cal. Code Regs. tit. 17, § 93106)
California Air Resources Board (CARB) · USA – California · Law / ordinance
Scope. Restricts the use, sale and supply of 'restricted material' as surfacing (unpaved roads, parking lots, road shoulders), to limit public exposure to naturally occurring asbestos (NOA).
What it regulates. Sets the maximum permissible asbestos content of aggregate/serpentine material used for surfacing; determined by CARB Method 435.
Where it ends. A content limit on the bulk material, NOT an airborne-concentration limit (emission/work controls for quarrying/grading are in § 93105).
Our reading: History: original 1990/1991 with 5 %; CARB decision July 2000, effective 2001, lowered it to < 0.25 %. A residual 5 % reference remains in § 93106(f)(9)(A)(3) (if compliant material is unavailable).
CARB Method 435: CARB Method 435 - Determination of Asbestos Content of Serpentine Aggregate (17 CCR § 94147)
California Air Resources Board (CARB) · USA – California · Analysis method
Scope. Laboratory test method to quantify the asbestos content of serpentine aggregate (storage piles, conveyor belts, surfaces such as roads/shoulders/parking lots).
What it regulates. Polarized light microscopy (PLM) after pulverization to < 200 Tyler mesh (≈74-75 µm) and a 400-point count; range 0-100 %, lower detection limit 0.25 %.
Where it ends. A pure measurement method, no pass/fail limit; the 0.25 % detection limit is the source of the < 0.25 % value in ATCM § 93106.
Our reading: Precision: the original 1991 method specifies '200 Tyler mesh' (= 74 µm); '75 µm' is the metric equivalent (used in later CARB guidance). The method was formally adopted on 6 June 1991 (recommended April 1990).
USA
ASTM D7521: ASTM D7521-22 - Standard Test Method for Determination of Asbestos in Soil
ASTM International, Committee D22.07 · USA · Analysis method
Scope. Procedure to identify and estimate the asbestos concentration in soil (dried); optionally as asbestos structures per gram. Primarily polarized light microscopy (PLM), optionally TEM (with SAED + EDXA).
What it regulates. Identification + quantification of asbestos in soil (wt-% and optionally structures/gram).
Where it ends. Soil-specific - not air and not building products (ISO 22262 / E-series). The stated analytical sensitivity (0.25 % or 0.1 % by weight) is a method parameter, not a legal limit.
Our reading: Current edition -22 (supersedes -13/-16).
EPA ABS (El Dorado Hills): US EPA Region 9 - El Dorado Hills NOA Multimedia Exposure Assessment (Activity-Based Sampling, 2004/2005)
US Environmental Protection Agency, Region 9 (mit ATSDR) · USA · Analysis method
Scope. Exposure study: activity-based personal air sampling during simulated recreational activities on NOA-bearing ground vs. static reference samples (El Dorado Hills, California).
What it regulates. Measures inhaled fibre concentration when the ground is disturbed. Finding: up to ~43x the reference (cycling ≈43x, baseball ≈22x, soccer ≈16x).
Where it ends. A research finding/method, NOT a legal limit. Supports the argument that static measurements understate real bystander exposure.
Our reading: Provenance note: the methodology and the directional finding (activity >> reference) are in the EPA report; the exact '43x' factor is confirmed as an EPA/ATSDR statement on an official .gov source, but not as a verbatim string in the report body (which carries per-location data tables).
Netherlands
NEN 5707: NEN 5707+C2:2017 - Soil - Investigation and sampling of asbestos in soil and soil stockpiles
NEN (Koninklijk Nederlands Normalisatie-instituut) · Netherlands · Analysis method
Scope. Investigation strategy and the inspection and sampling for determining asbestos in soil and soil batches (regardless of asbestos form).
What it regulates. A field/sampling and inspection standard for soil; laboratory analysis follows the companion standard NEN 5898.
Where it ends. Not air and not the analytical lab determination (NEN 5898); for C&D waste and granulate use NEN 5897.
Our reading: The split 'soil with < 50 % foreign material -> NEN 5707, otherwise NEN 5897' sits in the paywalled scope clause; confirm the exact percentage before publishing. Current version +C2:2017 (the 2015 base is withdrawn).
NEN 5897: NEN 5897+C2:2017 - Investigation and sampling of asbestos in construction and demolition waste and recycling granulate
NEN (Koninklijk Nederlands Normalisatie-instituut) · Netherlands · Analysis method
Scope. Investigation strategy and the inspection and sampling for determining asbestos in unprocessed and processed construction & demolition waste and recycling granulate.
What it regulates. A sampling/inspection standard for C&D waste and granulate.
Where it ends. Not soil (-> NEN 5707), not air, not the analytical lab determination (NEN 5898).
Our reading: Practical rule: > 50 % stony/C&D material -> NEN 5897; > 50 % soil -> NEN 5707. The exact percentage sits in the paywalled scope clause; confirm before publishing.
International (ISO)
ISO 14966: ISO 14966:2019 - Ambient air - Determination of numerical concentration of inorganic fibrous particles - Scanning electron microscopy method
Scope. Scanning electron microscopy method for the numerical concentration of inorganic fibrous particles in ambient air; EDXA discriminates asbestos compositions (serpentine, amphibole) from gypsum and other inorganic fibres.
What it regulates. Number concentration (fibres per volume) of inorganic fibres in ambient air.
Where it ends. Air measurement (SEM) - not bulk/soil and not a mass/content method.
Scope. Methods for sampling bulk materials and the qualitative identification of asbestos in commercial bulk materials; primarily polarized light microscopy with dispersion staining, optionally SEM/TEM with EDXA.
What it regulates. Qualitative identification (presence/absence) of asbestos in bulk material.
Where it ends. Not quantitative (that is Parts 2/3) and not for air.
Scope. Quantitative determination of asbestos mass fractions (below approximately 5 %) in bulk materials, vermiculite and products made from them, via gravimetric matrix reduction and microscopical quantification.
What it regulates. Quantitative asbestos mass fraction in bulk material (gravimetric + microscopical).
Where it ends. Quantification by X-ray diffraction is the separate Part 3 (ISO 22262-3); not for air.
Our reading: Correction: Part 2 is NOT TEM-specific but 'gravimetric and microscopical methods'. New 2nd edition 2026-01-15 supersedes the 2014 edition. Confirm the exact 2026 scope wording before publishing.
Terms: value types and protection goals
In this field, harm rarely comes from a wrong number; it comes from confusing the terms. The "Value type" column in the table above classifies each value functionally, regardless of what its own source calls it (CLP, for instance, calls its 0.1 % threshold a "generic concentration limit"). The second axis, the protection goal, sorts each standard by whom or what it protects; that is the same axis the catalogue above can be grouped by. Both vocabularies at a glance:
Value types
Limit value
Legally binding maximum; exceeding it is a violation or triggers mandatory measures.
Threshold value
A value whose crossing triggers a legal status or classification (e.g. a "contains asbestos" status), not itself an exposure cap.
Orientation value
A non-binding guidance/orientation value with no direct legal consequence.
Acceptance concentration
Risk-based value in the German limit framework (TRGS 910): the boundary between the low and medium risk range.
Tolerance concentration
Risk-based value (TRGS 910): the upper bound of tolerable risk, above which activities are generally impermissible.
Protection goals
Occupational protection
Protection of workers from asbestos exposure at the workplace (exposure limits, work and abatement rules).
Public and environmental protection
Protection of the general public and the environment outside the workplace (ambient air, public surfaces, residents).
Analysis & material assessment
Methods to detect and quantify asbestos in material and air samples, and the classification of materials.
Remediation & deconstruction
Rules for handling, removing, and deconstructing asbestos-containing materials.
Extraction & mining law
Mining-law rules governing the extraction of mineral raw materials that may contain naturally occurring asbestos.
Classification & placing on market
Substance-law classification, labelling, and market-placing restrictions (CLP, REACH).
Waste
Waste-law classification and disposal of asbestos-containing materials.
Threshold comparison: which standard measures what?
The same word ("asbestos") stands, across the following instruments, for physically different quantities. The table places a selection of central standards side by side and shows which quantity each measures and which threshold, if any, it sets itself. Material mass content (% by mass) and airborne fibre concentration (fibres/m³) cannot be converted into one another; a method built for one domain does not answer the question of the other.
Asbestos in soil — field, sampling and inspection procedure (lab analysis per NEN 5898)
–
Analysis & material assessment
Notably, most analysis methods set no threshold of their own ("—"); they measure, and statute attaches the legal consequence. And even within the mass-content rows not every standard measures the same thing: the decisive difference lies in the sample-preparation step: respirable dust in Procedure 2 of TRGS 517 versus full pulverisation in CARB Method 435. The next section unfolds that procedural question.
Methodological context: what the TRGS-517-Annex-2-Procedure-2 method measures, and what it does not
This section places the procedure normatively anchored in Annex 2 of TRGS 517 in methodological context. The contextualisation is not a critique of the procedure within its scope, but a clarification of which physical question it answers and which it does not. The distinction matters because different asbestos-assessment situations require different quantities.
1. What the method measures
The TRGS-517-Annex-2-Procedure-2 method mathematically combines two measurements: first the asbestos mass fraction in the respirable dust (E-Staub, grain size < 100 µm) that a sample releases in a standardised dustability test under worst-case conditions, and second the mass fraction of that respirable dust in the total falling sample. The product of the two values yields the "asbestos mass content referenced to the falling mass". This quantity describes the asbestos fraction that, during the standardised pouring or processing event, passes into the respirable dust, rescaled to the total mass of the analysed sample.
The method therefore answers a well-defined question of occupational protection: how much asbestos does a concrete processing activity release into respirable workplace breathing air, under worst-case conditions? Within that scope the method is established, technically valid, and normatively anchored in Annex 2 of TRGS 517.
2. What the method does not measure
The method provides no statement about the total asbestos mass content of the analysed sample after complete mechanical comminution. It also provides no statement about the asbestos quantity that the material can release over years of mechanical wear outside the processing facility. Both follow from the geology of the analysed material.
In serpentinites, chrysotile veins are macroscopic structural elements in the millimetre-to-centimetre range; after mechanical comminution they distribute across all grain-size fractions, not just the respirable-dust fraction. In amphibole-asbestos-bearing rocks (actinolite, tremolite), the amphibole crystals are prismatic, often acicular, and likewise occur across several grain-size ranges. Restricting the analysis to the < 100 µm fraction under worst-case dustability conditions does not capture this distribution.
A temporal aspect adds to this: serpentine aggregate used in public road construction is continuously further-comminuted by traffic, weather, cleaning, and maintenance. The grain-size distribution at year zero after application differs systematically from the distribution at year five or year ten. A method that captures only the year-zero respirable-dust fraction under a defined worst-case pouring event does not represent the year-five or year-ten material. This observation is explicitly documented in the peer-reviewed literature on the analytics of naturally occurring asbestos in aggregates (Cavallo 2020, full reference below).
3. Where the problem arises: scope transposition
The TRGS-517-Annex-2-Procedure-2 method is methodologically consistent within its scope. Transposing its result quantity ("asbestos mass content referenced to the falling mass") into a different assessment context, such as the assessment of multi-year resident exposure on a gravel road, leads to a methodological discrepancy: three physically distinguishable mass fractions can equally be called "percent asbestos", and they can differ on the same physical material by orders of magnitude.
First quantity: the asbestos fraction in the event-specific respirable-dust fraction of a concrete pouring event (what Procedure 2 captures in its first measurement step).
Second quantity: the asbestos fraction in the falling sample after rescaling via the respirable-dust mass fraction (what Procedure 2 reports as the final value).
Third quantity: the asbestos fraction of the fully pulverised sample (what CARB Method 435 determines after pulverisation to ≤ 75 µm under polarised-light microscopy).
These three quantities measure different questions. The selection of the appropriate quantity is a methodological question, not a value judgement on the procedures themselves. For the assessment of a single processing activity in the workplace, the second quantity is relevant. For the assessment of the material's inventory ("how much asbestos does this material contain in total"), the third quantity is relevant. For the assessment of multi-year resident exposure on a gravel road, the methodologically closer quantity is the third, because the material approaches the pulverisation state progressively through years of mechanical wear.
A further observation: even within a single procedure, mass fraction does not linearly predict fibre-release potential. Two samples with identical asbestos mass percentages can release vastly different fibre counts depending on their fibre-diameter distribution. Mass concentration and fibre count are physically different quantities, and the health-relevant metric is inhaled fibre dose, not mass (Lippmann 1990; cf. IARC 2012). Accordingly, the WHO methodology measures and assesses asbestos as a fibre-number concentration, not gravimetrically.
4. Model calculations: Procedure 2 applied to serpentinite products from the Rechnitz window
To illustrate the Procedure 2 calculation steps, we present three model calculations with input values corresponding to the geological range of the Rechnitz window. Each model calculation comprises product samples at different grain sizes with their intermediate values (dust fraction, chrysotile and amphibole content in the dust) and the rescaled total asbestos content. The complete dataset (18 samples, three model calculations, with chrysotile/amphibole breakdown) is available as a CSV download.
Model calculation A: seven product samples, mixed chrysotile-amphibole profile
Sample
Grain size (mm)
Dust fraction (%)
Chrysotile in dust (%)
Amphibole in dust (%)
Total asbestos (%)
Factor
A
0/2
5.98
22.3
6.9
1.7
17 ×
B
0/2
11.1
4.7
27.9
3.6
36 ×
C
0/16
7.5
10.1
26.8
2.8
28 ×
D
0/32
7.3
4.3
26.6
2.3
23 ×
E
8/11
1.48
6.7
18.5
0.4
4 ×
F
16/22
4.9
11.4
9.4
1.0
10 ×
G
40/70
5.95
6.0
17.1
1.4
14 ×
Samples A and B are two different products of the same grain size 0/2. The asbestos content in the dust comprises chrysotile and amphibole (tremolite/actinolite); Model calculation A shows a substantial amphibole fraction across all grain sizes.
Observation 1: one dataset, seven products, ninefold range. The calculated asbestos mass fractions range from 0.4 to 3.6 % (factor 9). All seven samples come from the same product set. The variation is primarily methodological, not mineralogical. The coarser the grain, the less dust the dustability test releases, the lower the result. Even two samples of the same grain size (A and B, both 0/2) yield different values (1.7 vs 3.6 %), showing the method's scatter in dust-intensive fractions.
Observation 2: the implicit assumption (>100 µm = 0 % asbestos). The rescaling [asbestos in dust] × [dust fraction] yields the same numerical result as the assumption that the fraction above 100 µm contains 0.0 % asbestos. Were this assumption geologically correct, different grain sizes of the same rock should yield similar total fractions. The ninefold range shows that the variation is driven by the denominator (dust fraction), not by the actual asbestos distribution in the rock.
Observation 3: every value above the 0.1 % threshold. The threshold comes from the German GefStoffV (§ 11 (1) No. 1), concretised in TRGS 517; Austria has no independent material threshold and draws on the German procedure (see Regulatory framework). Every sample exceeds the threshold: the lowest fourfold (Sample E, 0.4 %), the highest thirty-sixfold (Sample B, 3.6 %). A methodology that systematically produces lower values than a total-material analysis cannot bring this material below its own threshold.
Context. Observations 1 and 2 illustrate the scope transposition described in section 3. An analysis under CARB Method 435 (full pulverisation to ≤ 75 µm, then PLM point-counting) would produce values substantially above the Procedure 2 rescalings, because the entire asbestos mass of the rock is captured, not only the fraction released during the dustability test.
Model calculation B: six product samples, balanced chrysotile-amphibole profile
Sample
Grain size (mm)
Dust fraction (%)
Chrysotile in dust (%)
Amphibole in dust (%)
Total asbestos (%)
Factor
A
0/16
2.31
10.8
13.6
0.6
6 ×
B
0/63
2.55
15.4
16.8
0.8
8 ×
C
2/4
1.05
17.7
14.2
0.3
3 ×
D
11/16
3.71
29.6
14.7
1.6
16 ×
E
22/32
3.52
19.2
14.9
1.2
12 ×
F
63/180
3.93
29.2
~0
1.1
11 ×
Mineralogical observation. Model calculation B shows a roughly equal chrysotile and amphibole fraction in the respirable dust across most grain sizes. The exception is the coarsest fraction (63/180 mm): amphibole drops to near zero while chrysotile remains dominant. A possible explanation is that prismatic amphibole crystals release less fine dust during coarse-grain processing than the fibrous, cleavable chrysotile veins. The finding shows that the mineral composition of the released dust is grain-size-dependent, not just the quantity.
Range: 0.3 to 1.6 % (factor 5.3). All samples above the 0.1 % threshold (3-fold to 16-fold).
Model calculation C: five product samples, near-pure chrysotile profile
Sample
Grain size (mm)
Dust fraction (%)
Chrysotile in dust (%)
Amphibole in dust (%)
Total asbestos (%)
Factor
A
0/16
4.16
36.1
~0
1.5
15 ×
B
0/32
5.17
17.6
~0
0.9
9 ×
C
0/63
6.61
40.4
~0
2.7
27 ×
D
2/4
1.18
52.9
3.2
0.7
7 ×
E
4/6
0.55
34.0
~0
0.2
2 ×
Mineralogical observation. Model calculation C is mineralogically distinct: the respirable dust consists almost entirely of chrysotile (amphibole appears only once, 3.2 % in the 2/4 fraction). The chrysotile concentration in the dust is exceptionally high: in the 2/4 fraction, 52.9 % of the respirable dust is chrysotile. Nevertheless, the Procedure 2 rescaling yields only 0.7 % total asbestos for this fraction, because the dust fraction is low at 1.18 %. The 4/6 fraction shows the lowest value in the entire complex at 0.2 % (still factor 2 above the threshold); it also has the lowest dust fraction (0.55 %).
Range: 0.2 to 2.7 % (factor 13.5). All samples above the 0.1 % threshold (2-fold to 27-fold).
Summary across three model calculations
18 samples across three model calculations with input values from the same geological complex (Rechnitz window). Every single sample exceeds the 0.1 % threshold from § 11 (1) No. 1 GefStoffV. The range spans from 0.2 % (factor 2) to 3.6 % (factor 36). The methodology critique from observations 1 through 3 is not dataset-specific; it follows from the calculation logic of the procedure and reproduces across all three datasets.
The three model calculations differ mineralogically: calculation A shows a mixed chrysotile-amphibole profile, calculation B a roughly equal ratio, calculation C an almost pure chrysotile profile. This variation is geologically expected (different metamorphic histories within the same ophiolitic complex) and health-relevant, because the cancer risk of amphibole asbestos is epidemiologically higher than that of chrysotile (Hodgson and Darnton 2000 for amosite and crocidolite; for tremolite and actinolite the epidemiological data is thinner, but the direction of the finding is consistent).
5. Asbestiform or cleavage fragment: the central NOA distinction
With naturally occurring asbestos in amphibole rock, a question arises that does not occur with industrial asbestos: does an acicular amphibole particle that meets the WHO geometry (length > 5 µm, diameter < 3 µm, ratio > 3:1) but did not grow in asbestiform habit count as an asbestos fibre?
Two growth habits.Asbestiform fibres grow unidirectionally in bundles of fine, individually separable fibrils; they are flexible, high in tensile strength, and retain their length-to-diameter ratio when split. Cleavage fragments, by contrast, arise from the fracture of a non-asbestiform crystal; they are brittle and inflexible.
The regulatory gap. The counting methods (WHO fibre criteria, SEM/PCM) capture geometry, not growth habit: some cleavage fragments meet the counting criteria and are counted as fibres. Whether non-asbestiform cleavage fragments of equal dimensions have the same carcinogenic effect as asbestiform fibres is scientifically disputed. Part of the literature attributes a lower risk to them: a review of occupational cohorts concludes that non-asbestiform amphiboles do not increase the risk of lung cancer or mesothelioma (Gamble and Gibbs 2008). The opposing position does not regard that lower risk as established and points out that no routine analytical method reliably separates asbestiform fibres from non-asbestiform particles of the same geometry (NIOSH 2011). No clear analytical boundary exists between the two.
Relevance to the Burgenland affair. Because part of the material contains amphibole asbestos, this distinction matters there (see the Burgenland page). We state both positions without presenting the open scientific question as settled.
The geochemistry behind it. The blog post Serpentinite, asbestos and the geology of the Rechnitz Window explains in detail why asbestiform growth and a cleavage fragment can carry the same geometry and composition at the crystal level, and why amphibole asbestos is more biodurable than chrysotile.
6. Scientific sources
Cavallo, A. (2020): "Aggregates and naturally occurring asbestos: the need of a correct analytical approach." EGU General Assembly 2020. ui.adsabs.harvard.edu/abs/2020EGUGA..22.3900C. The work argues explicitly that the analytical capture of asbestos in aggregates requires a methodology that accounts for the complete grain-size distribution; restriction to a single fraction is, the authors argue, insufficient for risk assessment of the end material.
USGS Open-File Report 2011-1188: "Reported Historic Asbestos Mines, Historic Asbestos Prospects, and Other Natural Occurrences of Asbestos in California." pubs.usgs.gov/of/2011/1188. Geological documentation of the serpentine-based NOA occurrences in California that form the geological background for the development of CARB Method 435 and the ATCM Surfacing Applications. Structurally parallel to the Burgenland situation (serpentine occurrences in the Rechnitz window).
IARC Monograph Volume 100C (2012): "Arsenic, Metals, Fibres, and Dusts." publications.iarc.fr/120. The International Agency for Research on Cancer classifies all six classical asbestos minerals (chrysotile and the five amphibole asbestos species) in Group 1 (carcinogenic to humans). For risk assessment: no threshold dose, linear dose-response with cumulative fibre exposure.
Hodgson, J. T. & Darnton, A. (2000): "The quantitative risks of mesothelioma and lung cancer in relation to asbestos exposure." Annals of Occupational Hygiene 44(8):565–601. academic.oup.com/annweh/44/8/565. A meta-analysis of occupational cohorts: the exposure-specific mesothelioma risk of the three commercial asbestos types is broadly 1 : 100 : 500 (chrysotile : amosite : crocidolite). This is the quantitative evidence for the markedly higher potency of the amphibole asbestos types.
Lippmann, M. (1990): "Effects of fiber characteristics on lung deposition, retention, and disease." Environmental Health Perspectives 88:311–317. pmc.ncbi.nlm.nih.gov/articles/PMC1568011. Fibre dose, fibre dimension, and biopersistence — not mass — govern fibre effects; longer, thinner fibres are more toxic. The scientific basis for measuring and assessing asbestos as a fibre count (fibres/m³) rather than gravimetrically.
Gamble, J. F. & Gibbs, G. W. (2008): "An evaluation of the risks of lung cancer and mesothelioma from exposure to amphibole cleavage fragments." Regulatory Toxicology and Pharmacology 52(1 Suppl.):S154–S186. pubmed.ncbi.nlm.nih.gov/18396365. A review of occupational cohorts concluding that non-asbestiform amphiboles (cleavage fragments) do not increase the risk of lung cancer or mesothelioma. Source for the "lower risk" position in section 5.
NIOSH (2011), Current Intelligence Bulletin 62: "Asbestos Fibers and Other Elongate Mineral Particles: State of the Science and Roadmap for Research." DHHS (NIOSH) Publication No. 2011-159. cdc.gov/niosh/docs/2011-159. Introduces the term "elongate mineral particle (EMP)" and states that the health effects of non-asbestiform EMPs remain uncertain and that no routine analytical method reliably separates asbestiform fibres from non-asbestiform particles. Source for the open-question position in section 5.
Licence & citation
This dataset and page are licensed under Creative Commons Attribution 4.0 (CC BY 4.0). The data may be shared and adapted (including commercially) as long as Ungiftig is credited as the source.
Ungiftig FlexCo (2026): Asbestos Standards: Rules and Limit Values at a Glance. Version 1.2.0 (last reviewed 2026-06-14). https://ungiftig.at/en/asbestos-standards/. Licence: CC BY 4.0.
BibTeX
@misc{ungiftig_asbest_normen_2026,
author = {{Ungiftig FlexCo}},
title = {Asbestos Standards: Rules and Limit Values at a Glance},
year = {2026},
version = {1.2.0},
url = {https://ungiftig.at/en/asbestos-standards/},
note = {last reviewed 2026-06-14, CC BY 4.0}
}
Last reviewed: 2026-06-14 · Version 1.2.0
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